EC11: Infrastructure

Object

Representation ID: 4191

Received: 21/12/2022

Respondent: Mr John Marsh

Legally compliant? No

Sound? No

Duty to co-operate? No

See attachment

Support

Representation ID: 4322

Received: 22/12/2022

Respondent: Dudley Metropolitan Borough Council

Support this policy, particularly the reference to devleopers and landowners being expected to work positively with neighbouring authorities on infrastructure provision.

Comment

Representation ID: 4482

Received: 22/12/2022

Respondent: Bloor Homes

Agent: Evolve Planning & Design

Bloor Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected settlements and where appropriate deliver new infrastructure benefits alongside new development.
Land East of Bilbrook is a larger strategic proposal that can facilitate significant infrastructure provision (lists a number of infrastructure opportunities identified within the Infrastructure Delivery Plan).
Engagement with key infrastructure providers through the Local Plan
review process has taken place through the masterplanning process which has informed the Infrastructure Delivery Plan (IDP) however further engagement is necessary to provide absolute clarity in respect of infrastructure requirements, costs and phasing of delivery. This will inform the strategic masterplan and any associated design code.

Comment

Representation ID: 4515

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected
settlements and where appropriate deliver new infrastructure benefits alongside new development.
Cameron Homes is committed to engaging with the District Council, and other stakeholders to explore all infrastructure requirements to inform future
iterations of the Infrastructure Delivery Plan and the emerging proposal for Land East of Wolverhampton Road.

Comment

Representation ID: 4543

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected
settlements and where appropriate deliver new infrastructure benefits alongside new development.
Cameron Homes is committed to engaging with the District Council, and other stakeholders to explore all infrastructure requirements to inform future iterations of the Infrastructure Delivery Plan and the emerging proposal for Land adjoining Saredon Road.

Comment

Representation ID: 4569

Received: 22/12/2022

Respondent: Cameron Homes Ltd

Agent: Evolve Planning & Design

Cameron Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected
settlements and where appropriate deliver new infrastructure benefits alongside new development.
Land at Landywood Lane is providing infrastructure in conjunction with a phased proposal, to include the delivery of a car park for Landywood Railway
Station, a new Country Park and land for allotments.
Cameron Homes is committed to engaging with the District Council, and other stakeholders to explore all infrastructure requirements to inform future iterations of the Infrastructure Delivery Plan and the emerging proposal for Land at Landywood Lane.

Comment

Representation ID: 4598

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Evolve Planning & Design

Taylor Wimpey supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected settlements and where appropriate deliver new infrastructure benefits alongside new development.
Land at Cross Green is a larger strategic proposal that can facilitate significant infrastructure provision (lists infrastructure to be provided).
Taylor Wimpey is committed to engaging with the District Council, and other stakeholders to explore infrastructure requirements to inform future iterations of the Infrastructure Delivery Plan and the emerging proposal for Land at Cross Green.

Comment

Representation ID: 4625

Received: 22/12/2022

Respondent: Four Ashes Road LTD

Agent: Evolve Planning & Design

Four Ashes Road Ltd supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better connected
settlements and where appropriate deliver new infrastructure benefits alongside new development.
Four Ashes Road Ltd is committed to engaging with the District Council, and other stakeholders to explore all infrastructure requirements to inform future iterations of the Infrastructure Delivery Plan and the emerging proposal for Land at Four Ashes Road, Brewood.

Comment

Representation ID: 4682

Received: 22/12/2022

Respondent: Keon Homes

Agent: Evolve Planning & Design

Keon Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected settlements and where appropriate deliver new infrastructure benefits alongside new development.

Comment

Representation ID: 4723

Received: 22/12/2022

Respondent: Lovell Homes

Agent: Evolve Planning & Design

Lovell Homes supports the Council’s proposed infrastructure led strategy which seeks to focus development towards larger and better-connected
settlements and where appropriate deliver new infrastructure benefits alongside new development.
Lovell Homes is committed to engaging with the District Council, and other stakeholders to explore all infrastructure requirements to inform future iterations of the Infrastructure Delivery Plan and the emerging proposal for Land at Pool House Road.

Object

Representation ID: 4822

Received: 24/02/2023

Respondent: Trine Developments Limited

Agent: Cerda Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We support the provisions of Policy EC11 and the need for developer contributions and infrastructure provision in principle. However, as drafted, the policy makes no reference to the provisions of the CIL tests, which
should be explicit. As a result, the policy is imprecise, and it is not clear whether its operation would be discordant and at variation with the CIL provisions. The policy should be modified to expressly refer to the three CIL tests
and furthermore make clear that developer contributions and infrastructure provision will only be required where each of the three tests are demonstrably met.

Object

Representation ID: 5185

Received: 22/12/2022

Respondent: Richborough Estates

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Assessment of cumulative impact and mitigation must be proportionate.

Object

Representation ID: 5267

Received: 21/12/2022

Respondent: Mr Brian Wyatt

Legally compliant? No

Sound? No

Duty to co-operate? No

The Local Plan fails to reflect its own Site Requirements in Appendix C and has not met its obligations in Policy EC11. Site 036c, land south of Stafford, is remote from education, health, sports, and recreation facilities. the nearest facilities are located within Stafford Borough. It is not within the gift of SSDC to ensure provisions are requirements. It is understood that SBC representations relate to their lack of resource for these requirements over and above their own requirements to meet the demand from substantial house building in the borough.

The only viable public transport options from the site are in to Stafford. Use is already excessive with extensive delays at peak times.

If proposed residents are to use the Acton Hill Road towards Dunston, Penkridge, or M6 Junction 13, this is a narrow lane with poor sight lines and is already congested with private and commercial traffic. It is not safe for cyclists. Acton Trussell is already affected by 'rat-run' traffic from Stafford through the the M6 seeking to avoid the congested A449.

SSDC have generated an appearance of consultation with SBC, when in reality the consultation has been rushed and is a single presentation of what has already been decided.

There is no requirement for houses on site 036c other than the meet now rescinded government housing targets and provision for the Black Country. The site is remote from the Black country. The site is contiguous with Stafford which is already committed to over 7,000 houses on brownfield sites.

The site is valuable farming land and a biodiversity link.

The location of site 036c is considered not legally compliant, sound, or compliant with the DtC. This is due to over reliance on infrastructure provision within SBC which SSDC has an inability to affect. There has been a lack of effective consultation with those who will be most affected. The developer has made at least two previous applications to build on this land. Should this site be permitted there is little confidence that SSDC will prevent further extensions that will effectively link Acton Trussell with Wildwood contrary to Strategic Objectives 4, 5, 9, and Policy HC17.

The plan should propose a fewer quantum of housing development and site 036c should be deleted from the plan.

Support

Representation ID: 5312

Received: 22/12/2022

Respondent: Miller Homes

Agent: Pegasus Group

Policy is considered sound subject to our comments.

We stress the importance that the Infrastructure Delivery Plan is up to date at the time of examination to ensure that the viability implications of the proposed strategic infrastructure have been fully accounted for in the plan, given current rates of inflation, particularly in respect of construction costs.

Object

Representation ID: 5324

Received: 22/12/2022

Respondent: Taylor Wimpey UK Ltd

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Assessment of cumulative impact and mitigation must be proportionate. Policy should commit SSC to work actively with neighbours on cross boundary infrastructure issues.

Comment

Representation ID: 5363

Received: 20/12/2022

Respondent: Cameron Homes Ltd

Agent: Pegasus Group

Policy EC11 commits SSDC to work with and support infrastructure providers and also offer support for the delivery of infrastructure. This is broadly supported, but any assessment of cumulative impact and mitigation requested must be proportionate and CIL Regulation 122 compliant. The policy should be explicit that this is the case.

Object

Representation ID: 5383

Received: 09/12/2022

Respondent: Persimmon Homes West Midlands

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

We note that the policy commits the Council to work with and support infrastructure providers and also offers policy support for this. Any assessment of cumulative impact and mitigation requested must be proportionate and CIL Regulation 122 compliant. The policy should be explicit that this is the case.
The policy is considered unsound, as it is neither justified nor consistent with national policy for the reasons set out above.

Object

Representation ID: 5403

Received: 22/12/2022

Respondent: Rigby Estates LLP

Agent: Pegasus Group

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Ensure that Infrastructure Delivery Plan is up to date at the time of the examination.